The Internal Revenue Service's rejection of a taxpayer's offer in compromise of $28,000 for a tax liability of more than $150,000 was not an abuse of discretion, because the taxpayer failed to prove any special circumstances warranting During the CDP hearing the settlement officer advised petitioner that the OIC would not be accepted because petitioner’s…
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About: Ronald Marini
Recent Posts by Ronald Marini
Swiss – US Tax Deal Terms Not Likely to Ease if Romney wins
A Romney White House would make the same demands as the current administration has before agreeing to wipe the slate clean for 11 Swiss banks suspected of helping wealthy Americans evade taxes, Switzerland's Finance Minister said. Switzerland needs the tax deal so that it can normalise its banking relations with the United States, but Widmer-Schlumpf…
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Bradley Birkenfeld awarded $104 million (13% ) as UBS tax case whistleblower
U.S. tax authorities have awarded $104 million to a whistleblower in a major tax fraud case against Swiss bank UBS AG that widened a government crackdown on Americans avoiding taxes in Switzerland, his lawyers said on Tuesday. This approximately 13% of the amount the Government recovered from UBS ( $780 million in fines, penalties, interest…
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Last Chance for Voluntary Disclosures before FATCA becomes effective in 2013!
January 1, 2013 is the effective date of the Foreign Account Tax Compliance Act (FATCA) and with its implementation the associated FATCA disclosures. FATCA ends historical bank secrecy as previously relied on by many US depositors. In anticipation of FATCA implementation, the IRS, revised its Frequently Asked Questions (FAQs), clarifying many uncertainties in the…
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